On 6 March 2024, the “non-dom” regime in the United Kingdom was abolished, which allowed natural persons resident but not domiciled in the UK to tax only English-source income and capital gains, exempting those realized outside the British territory (https://www.gov.uk/tax-foreign-income/non-domiciled-residents).
To date, the maximum duration period of this status is 15 years, as envisaged for the flat tax of 100,000 euros in force in Italy since 2017.
Despite the same duration, the two regimes differ in the obligation (provided for the “non-dom regime”) to pay taxes only starting from the 8th year of use, while the 100,000 euros are due in Italy on an annual basis .
In any case, the “remittance basis principle” rule involves the taxation of capital gains and income “returned” to English territory.
Once the “non-dom” regime is abolished in the United Kingdom, there will most likely be the exit of many residents from the United Kingdom who will choose a country with more favorable taxation, including Italy as introducer, starting from 2017, of the optional substitute tax regime for the so-called New Residents – Flat Tax of 100,000 Euros – see https://www.studiobcz.it/en/high-net-worth-en/
The choice of this last optional regime must be weighed by paying attention to the new requirements for the existence of tax residence pursuant to Legislative Decree no. 209/2023, i.e. the domicile understood as the place where the person’s personal and family relationships mainly develop; residence pursuant to the civil code and physical presence, which also considers “day’s fractions”.
For any further clarification or information, contact us for a fee quote for a feasibility study and a professional opinion accompanied by a tax convenience simulation regarding the tax planning opportunities.
